Draft City Plan Part One Brighton & Hove City Council's Local Development Framework May 2012 Supporting Documents Statement of Consultation Consultation Statement City Plan Policy Options Papers for: Employment Housing Delivery Student Housing Park and Ride 17 October - 2 December 2011 Contents 1 Introduction 2 1.1 Role of the document 2 1.2 Community Involvement 2 2 Consultation on the City Plan - Policy Option Papers 3 Stage 2.1 Background 3 2.2 Who was consulted? 5 2.3 How were the public and other stakeholders 5 consulted? 2.4 Results of the City Plan Policy Option Papers 9 Consultation 2.5 How the representations were taken into account 10 Appendix 1 – Summary of written representations to policy 13 options Appendix 2 – Summary of issues from stakeholder events and 26 workshops Appendix 3 – Policy Options Summary Paper 40 Appendix 4 - Press releases and media articles 50 Appendix 5 – Consultation Portal Questions 66 Appendix 6 – List of Consultees 74 Appendices 7 (a) – (e) - Detailed representations from 90 consultees including an officer response (by Policy Option Paper) Consultation Statement 1 City Plan Policy Options Paper Oct – Dec 2011 1. Introduction 1.1 Role of this document 1 Brighton & Hove City Council is required under current planning regulations to submit a Consultation Statement to accompany the City Plan (Development Plan Document - DPD). This statement sets out how the city council has involved the community and stakeholders in the preparation of the draft City Plan Part 1 in accordance with the council’s adopted Statement of Community Involvement (SCI). This statement shows that the minimum requirements set out in the SCI’s have been met and exceeded. This document sets out: i) Who was consulted ii) How the public and other stakeholders were consulted iii) The main issues raised as a result of the consultation iv) How the representations have been taken into account Whilst the City Plan Policy Options Papers appear to represent the ‘first stage’ in consulting and engaging people on the City Plan it is important to note that the draft City Plan reflects much of the content of the withdrawn Core Strategy which was subject to extensive consultation. In addition to this, on a proportionate basis and when appropriate, stakeholders have been consulted on a continuous basis in order to help ensure the policy approach is sound. The Policy Options Papers addressed the key elements of change and were subject to wide-ranging formal public consultation. A Policy Options Summary Paper is set out in Appendix 3. 1.2 Community Involvement The council adopted its Statement of Community Involvement in September 2006 following examination by an independent planning inspector (please note SCI’s are no longer subject to examination). It sets out how, when and where the council will consult with local and statutory stakeholders in the process of planning for the local authority area, both in producing development plan documents and in carrying out the development control function. Consultation on the withdrawn Core Strategy and the emerging City Plan has been guided by the approach set out in the SCI, in particular to: • Enable communities to put forward ideas and suggestions and participate in developing visions, proposals and options for the city • Let communities know about emerging policies and proposals in good time • Consult on formal proposals 1 Regulation 25 (pre-submission consultation) of the Town and Country Planning (Local Development) (England) Regulations 2004 (as amended) Consultation Statement 2 City Plan Policy Options Paper Oct – Dec 2011 • Ensure that consultation takes place in locations that are widely accessible • Provide and seek feedback The SCI advocates various approaches to consultation. The council’s approach is to make the maximum use of early community and other stakeholder involvement especially when input and responses from individual and organisations would make a real difference to planning policy. Continuous involvement is and will be sought to help minimise the need for a lengthy and controversial examination. In addition to the council’s SCI, which is required in order to meet planning legislation, regard has been given to the Community Engagement Framework 2009 (CEF) developed by the Brighton and Hove Strategic Partnership, of which the council is a member. The CEF reinforces the principles of consulting and engaging with communities at an early stage to help ensure their input is meaningful and reflected in the development of a plan or policy. 2. Consultation on the City Plan - Policy Option Papers Stage 2.1 Background In July 2011, Council agreed to withdraw the Core Strategy to allow it to be updated and amended. This was agreed by the Secretary of State in September 2011 and the Core Strategy was withdrawn. The need to amend the document arose from soundness issues raised at an Exploratory Meeting with the appointed Planning Inspector in May 2010. This concerned the housing delivery strategy in the submitted document and the government’s expectation that council’s will set their own housing targets prior to the proposed removal of regional housing targets. The need to update the document also arises from the number of significant changes that have happened since the document was submitted to the Secretary of State two years ago. These include proposed changes to national legislation and guidance (Localism Act 2011 and the National Planning Policy Framework), reduced availability of government funding for capital projects and the completion of updated housing capacity studies (Strategic Housing Land Availability Assessment and Housing Requirements Trajectory Study). Reflecting these changes will help to secure an effective, up to date and sound document. As part of preparing the draft City Plan (which replaces the Core Strategy) it was considered necessary to undertake a period of consultation on four specific policy areas where important changes were proposed. These four policy areas were: housing targets and housing delivery, park and ride transport policy, employment policy and student housing policy. A Policy Options Summary Paper is set out in Appendix 3. The Options Papers were Consultation Statement 3 City Plan Policy Options Paper Oct – Dec 2011 subject to a Sustainability Appraisal (SA), a separate independent document, which critically examines the issues and options and tests them against the principles of sustainable development. As a result, the SA informed the preferred options set out in the Policy Options Paper. The benefit of consulting on the Policy Options Papers was that it allowed the full consideration of new and changed issues (that must be addressed in the City Plan) to be set in the context of new evidence and the changing national planning policy framework and the need for a sound plan. At the time of the consultation for the Policy Options Papers in late 2011, Planning Policy Statement 12 (PPS12) was in force and provided guidance on how communities should be involved in the process of developing plans. PPS12 has been deleted by the subsequent publication in March 2012 of the National Planning Policy Framework (NPPF). The principles enshrined in the NPPF guiding local authorities on community engagement and consultation is similar to previous government guidance. The NPPF advises that ‘a wide section of the community should be actively engaged’ … ‘to reflect a collective vision and a set of agreed priorities for the sustainable development of an area.’ The Localism Act also provides the framework for the way local plans are made including the level of influence local communities are to have in the development plan making process. Consultation on the Policy Options Papers was undertaken between 17 October and 2 December 2011 (just under 7 weeks). The following documents were produced at this stage: • City Planning Document Summary Leaflet • City Plan Frequently Asked Questions • Housing Delivery Option Paper • Employment Option Paper • Park and Ride Option Paper • Student Housing Option Paper • Final Sustainability Appraisal Report Sep 2011 • Final SA Non Technical Summary The documents / publications referred to above were made available on the dedicated City Plan section of the council’s website as well as the council’s consultation portal. Copies of the documents above and a list of consultation questions were also made available in the council’s City Direct offices in central Brighton, Hove and Portslade and at the council’s libraries; Jubilee Library (Brighton), Hove Library, Coldean Library, Hangleton Library, Hollingbury Library, Mile Oak Library, Moulsecoomb Library, Patcham Library, Portslade Library, Rottingdean Library, Saltdean Library, Westdene Library, Whitehawk Library, Woodingdean Library. 2.2 Who was consulted? Consultation Statement 4 City Plan Policy Options Paper Oct – Dec 2011 Under Regulation 25 (pre-submission consultation) of the Town and Country Planning (Local Development) (England) Regulations 2004 (as amended) there is a requirement to consult the public including specific and general organisations, as well as consulting those residents and/or businesses the local authority considers appropriate. The Policy Options Papers were therefore subject to extensive public consultation and engagement over a period which ran for just under 7 weeks. A full draft of the City Plan and detailed wording is to be consulted on for 8 weeks from 28 May 2012 to 20 July 2012. Both the policy options consultation and the draft City Plan consultation fall within Regulation 25 (pre- submission consultation) of the Town and Country Planning (Local Development) (England) Regulations 2004 (as amended). The Regulation 25 consultation will therefore cover more than a 14 week formal period which exceeds the SCI and Community Engagement Framework recommendations (especially when the consultation on the Core Strategy is taken into account). The list of consultees for the City Plan Policy Option Papers stage is attached as Appendix 6. 2.3 How were the public and other stakeholders consulted? Emails or letters were sent to the organisations and individuals who were logged as relevant consultees on the council’s LDF database.